Contact your Senators, other elected officials and those that may have influence. Tell them we need proven thick-wall casks, not cracking thin-wall canisters, for safer nuclear waste storage.

It is urgent the President and Congress stop the Nuclear Regulatory Commission (NRC) from allowing thin-wall cracking nuclear waste storage canisters. They cannot be inspected for cracks, let alone repaired. The NRC falsely assumes nothing will go wrong.

Replace thin-wall canisters with proven thick-wall casks that can be inspected, maintained and monitored to prevent major leaks and explosions. No one would buy a car that doesn’t meet those basic safety requirements, yet the NRC allows this to store highly radioactive nuclear fuel waste.

Each canister holds roughly a Chernobyl nuclear disaster. If we don’t get this right, nothing else will matter.

Transporting cracking thin canisters across the country to another location will not stop them from leaking or exploding.

Congress is focused on nuclear waste bills such as H.R. 3053, which propose to transport and store nuclear waste in unsafe thin-wall cracking canisters, with no plan if something goes wrong. This will no more make us safe than rearranging the deck chairs on the Titanic would stop it from leaking.

Demand the President and Congress force the NRC to do their job of protecting us. Require:

Stop loading nuclear waste in unsafe thin-wall canisters.

Replace existing thin-wall canisters with proven thick-wall metal casks that can be maintained and monitored to prevent major cracks and radioactive releases into our environment and that are transportable.

The NRC allows unsafe San Onofre nuclear waste storage by the beach at Camp Pendleton.

Southern California Edison refuses to use safer storage. Instead, they continue to load tons more nuclear waste at San Onofre in inferior thin-wall Holtec canisters that are already cracking. They have no plan in place to prevent or stop major radioactive releases into our communities. San Onofre is located near Trestles beach on Camp Pendleton in North San Diego county, near San Clemente.

San Onofre (SONGS): 89 times the Cesium-137 released from 1986 Chernobyl nuclear disaster. R. Alvarez June 2013

A nuclear disaster at San Onofre can result in major permanent evacuations across multiple counties.

Disneyland would likely be a ghost town.

Camp Pendleton would be useless.

We need to act now to stop this from happening.

Holtec almost dropped a San Onofre canister 18 feet.

Whistleblower Industrial safety inspector, David Fritch, revealed Holtec engineering and other safety problems at San Onofre nuclear waste facility. Fritch states the Holtec system is an engineering design problem and workers are understaffed, not qualified and not adequately trained to load nuclear fuel waste canisters into the Holtec dry storage system. He said safety is not the first priority with Holtec or Southern California Edison.

One loaded canister was hanging by a 1/4″ on a canister [MPC] Guide ring located about 4 feet down from the top of the hole). He and Edison said it came close to falling 18 feet into a Holtec canister storage hole — and this wasn’t the first time there were loading problems. See video of his statement and others from the August 10, 2018 Edison Community Engagement Panel (CEP) meeting. David Fritch transcript.

UMAX Holtec Shield Ring in the canister storage hole is part of an “MPC Guide” system designed to guide the nuclear waste canister into the hole. Instead, the Gussets guide the canister on to the lip of the guide ring. That lip should not be there. Works cannot see what they are loading. Also, the sides of all the canisters bump and grind against the sides of the metal guide ring as they are lowered into each hole, resulting in pit corrosion cracking. Once cracks start, they continue to grow through the canister walls. See NRC findings on NRC Special Inspection website

San Onofre has worst NRC safety complaint record in the nation.

San Onofre had the worst NRC safety complaint record in the nation from employees while the nuclear reactors were operating, so this whistleblower revelation is not surprising to those familiar with Southern California Edison’s history. San Onofre also had the highest rate of retaliation against employees.

The NRC and nuclear industry plan is to high radiation releases.

The NRC is allowing nuclear facilities to hide radiation levels from outlet air vents of canister concrete overpacks — where radiation levels will be highest from through wall cracks. Areva NUHOMS Amendment #4 request to NRC for their 24PT1 and 24PT4 dry storage canisters (DSC)(slide 6) requires only measuring peak radiation levels from inlet air vents of the AHSM concrete overpack. The NRC already approved this request for Calvert Cliffs in Maryland. Calvert Cliffs thin-wall canisters are up to 25 years old, cannot be inspected and could already be leaking, but they are not required to report radiation levels at the outlet air vents.

San Onofre radiation levels at older Areva NUHOMS canisters (up to 15 years old), already have high radiation levels, but the NRC will not tell us why. Radioactive counts per minute up to 2024 CPM (6.06 microsieverts per hour) at San Onofre waste storage inlet air vents on 9/6/2018.

Multiple Holtec canisters are scratched, but Edison has no method to find the scratches. Even microscopic scratches can remove the thin ~2nm (nanometre) layer of chromium oxide film on the stainless steel canisters, which creates pitting corrosion cracking by mechanical means. Once cracks start they can grow through the wall in 16 years (NRC). The NRC must resolve this issue for all the canisters, not just the ones with the near-drops. Holtec workers cannot see a canister when loading it in the hole, likely resulting in scratches to canisters as they try multiple times to aligned the canister properly in the hole. However, Edison and Holtec have nothing in place to inspect the outside or inside of the canisters or inspect for cracks. Edison admits in their August 10, 2018 press release: “Holtec was loading the spent fuel canister into the [steel lined concrete hole] Cavity Enclosure Container (CEC) on the dry cask storage pad when the canister got caught on an inner [MPC Guide] ring that helps to guide it into place. There is a very snug fit in the CECs, and it is not unusual for it to take the downloading team a few manipulations to get the canister aligned appropriately.”

No Decommissioning Trust Fund monies should be released to Edison by the California Public Utilities Commission (CPUC) until these issues are resolved. The Reactor Unit 2 and Unit 3 Trust Fund contained over $4.3 billion before Edison began loading Holtec thin-wall canisters. Edison knows these uninspectable canisters are vulnerable to short-term cracks and leaks and they have no plan if something goes wrong, but they continue to use them, anyway.

Videos reveal major nuclear waste storage problems at San Onofre

Southern California Edison response by Tom Palmisano

Camp Pendleton position on San Onofre waste storage

Tom Palmisano claims that Edison is in compliance with its Nuclear Regulatory Commission (NRC) license and Systems Analyst Donna Gilmore, SanOnofreSafety.org, objection to his claim by citing the NRC license condition requiring the ability to unload fuel from canisters back into the pool. She states Edison has no method to unload damaged canisters as required by their NRC license. Palmisano then admits this is a requirement of their NRC license, but plans to obtain an NRC exemption to destroy the pools once they are empty, in spite of having no other plan in place to unload damaged canisters. The only other option to unload defective canisters or inspect inside the canisters is using a large hot cell (a dry fuel handling facility filled with an inert gas so nothing explodes). Edison has no plans to build a hot cell.

Areva NUHOMS Amendment #4 request to NRC for their 24PT1 and 24PT4 dry storage canisters (DSC)(slide 6) would require only measuring peak radiation levels from inlet air vents of the AHSM concrete overpack. Leaking canister highest radiation levels will be from outlet air vents. The NRC already approved this request for Calvert Cliffs in Maryland. Calvert Cliffs thin-wall canisters are up to 25 years old, cannot be inspected and could technically already be leaking, but they are not required to report radiation levels at the outlet air vents.

In this August 9, 2018 CEP meeting video clip, Donna Gilmore called out Tom Palmisano on his lie that Edison is in compliance with their NRC license. He finally admitted their current license requires they must be able to return defective canisters back into the pool. They cannot do this as he admitted in the March 22, 2018 CEP meeting (second video below).

Southern California Edison (Tom Palmisano) admitted no nuclear facility has ever unloaded fuel assemblies from canisters back into the spent fuel pools, and they have no current method to do this (March 22, 2018 Community Engagement Panel meeting). He claims it is possible, yet there is no evidence to support this and no one has developed doing this in the decades they have been loading hot fuel in dry storage. He said the fuel is 200 to 300 degrees C. Water boils at 100 degrees C. He called it a “reflooding” problem. Yet Edison continues to load fuel in dry storage that is over twice as hot as their previous dry storage containers. The only other option to unload fuel on site is a hot cell, but Edison has no plans to build one.

In an August 10th San Diego Tribune article, Edison claims canisters are designed to with withstand an 18 foot drop, but has provided no evidence. On the contrary, the August 17, 2018 NRC Charter admits that a canister drop was not analyzed in the Holtec Final Safety Analysis (FSAR) approved by the NRC. And in Holtec HI-STORM canister (MPC) analysis of a canister drop inside a transfer cask, it states if a canister drops more than 11″, the canister must be inspected for damage. Since they cannot open or inspect canisters, they have no way to do this.

San Onofre: worst replacement steam generators in the nation

Edison mismanaged the replacement steam generator project, resulting in shutdown of the reactors on January 31, 2012. The NRC concluded Edison was at fault: “…a significant design deficiency in replacement steam generators, resulting in rapid tube wear of a type never before seen in recirculating steam generators.” In the NRC’s December 23, 2013 NRC Notice of Violation to Edison, they state: “…design control measures were not established to provide for verifying or checking the adequacy of certain designs”.

More Handouts

Thin-wall 1/2″ to 5/8″ nuclear waste cans contains roughly a Chernobyl nuclear disaster. They can’t be inspected, repaired, or maintained to prevent major radioactive leaks. They can crack and leak in the short-term

Each canister holds roughly a Chernobyl nuclear disaster — the amount of radioactive Cesium-137 and other radionuclides release from the 1986 Chernobyl nuclear disaster.

Thin-wall “Chernobyl cans” cannot be inspected (inside or out),repaired, maintained or monitored to PREVENT major radioactive releases into the environment.

Nuclear waste generators have no feasible plan in place to stop major radioactive releases.

Holtec HI-STORM UMAX two-layer lid with air vents. Radiation released through air vents. Thin-wall canister under each lid in steel lined concrete holes.

Peak radiation levels may not be reported to the public. The Nuclear Regulatory Commission (NRC) is allowing some facilities to exclude reporting radiation levels from the outlet air vents. This is where the highest levels will be when canisters have through-wall cracks.

Partially cracked canisters cannot be safely transported. Facilities have no method to inspect for cracks or the condition of the fuel and other contents of the canisters prior to shipment. Spent nuclear fuel can degrade after dry storage.

The Nuclear Waste Technical Review Board (NWTRB) recommends spent nuclear fuel and its containment must be monitored and maintained in dry storage in a manner to prevent hydrogen gas explosions for both short-term and long-term storage and transport. This is not currently being done and cannot bedone with the thin-wall welded canisters. It can only be done with thick-wall bolted lid casks, like those used in most of the world and at some US facilities. See NWTRB report to the United States Congress and the Secretary of Energy, Management And Disposal Of US Department Of Energy Spent Nuclear Fuel, NWTRB, December 2017.

The Nuclear Regulatory Commission (NRC) is aware of these issues, but refuses to require safe standards that would result in use of proven thick-wall metal casks (10″ to 19.75″ thick), used throughout the world, that can be inspected, maintained and monitored to prevent radioactive leaks.

NRC management makes decisions that value industry profits over public safety. They mislead the public, elected officials and others. They have mislead NRC Commissioners (who are appointed by the President and confirmed by the Senate).

Darrell Dunn, NRC materials corrosion engineer, claims there is not enough humidity at San Onofre for corrosion and cracking.

Darrell Dunn ignores frequent fog, on-shore winds and surf at the San Onofre nuclear facility and elsewhere. Dunn ignores Diablo Canyon 2-year old Holtec canister, filled with hot and highly radioactive nuclear fuel waste, that has a low enough temperature for moisture to stay on the canister surface and dissolve salts. He admits these are major triggers for chloride induced stress corrosion cracking. Instead, he references reports that exclude this data.

Two-year old Diablo Canyon Holtec canister has corrosive salt and low enough temperature for moisture to dissolve salt, a major trigger for stress corrosion cracking of thin-wall stainless steel canisters. Once a crack starts it can grow through the wall in 16 years. The thin-wall canister is inside the overpack. Access must be through the air vents, since the thin-wall canister does not protect from neutrons or gamma rays. Workers must stay below air vents to limit radioactive exposure.

Darrell Dunn erroneously stated at the Nuclear Waste Technical Review Board (NWTRB) Summer 2018 Board Meeting (June 13, 2018) that thin-wall canisters are not vulnerable to cracks in 20 years, but did not explain why.

Dunn did not disclose facts that would have contradicted his statement. Dunn stated there is inspection and repair technology, but did not mention once canisters are loaded with spent nuclear fuel they have no technology in place that can adequately find or measure cracks, let alone repair them. See Spent Nuclear Fuel Dry Storage Fact Sheet.

Dunn did not mention the NRC Aging Management Plan (NUREG-1927 Rev. 1) only requires one canister at each site to be “inspected”, unless they find problems. Since they cannot inspect, they cannot find problems.

Dunn did not mention the Aging Management Plan requires canisters with 75% through-wall cracks to be taken out of service, but there is no current method approved and in place that can to do that. (NUREG-1927 references the ASME Boiler and Pressure Vessel Code that specifies the 75% maximum, but NRC refused to add the term “75%” to the document.)

NRC Holtec transport cask certificate does not include unloading. This is up to the receiver of the cask.

Holtec’s application for a New Mexico UMAX CIS facility states canisters arriving leaking will be returned to sender. See SOS Holtec webpage for details about Holtec issues.

Leaking canisters are not approved for transport and receiving facilities have no method to stop leaks or replace canisters. Holtec’s New Mexico UMAX CIS proposal does not include a plan for cracking or leaking canisters nor a facility to replace canisters. The NRC has not approved Holtec’s UMAX CIS facility yet.

NRC is approving much higher heat loads and more fuel assemblies per canister, risking damage to the fuel and other components, increasing radiation levels near the canisters, and requiring decades more cooling before canisters can be transported.

The information about inability to replace failing canisters was not disclosed to the California Coastal Commission at the time Edison received their 20-year San Onofre Coastal Development Permit to store 73 Holtec UMAX nuclear waste canisters near the beach. It was disclosed at the March 22, 2018 Community Engagement Panel Meeting. The red arrow above shows location for the 73 Holtec canisters. Behind that are the 51 above ground existing Areva NUHOMS canisters already loaded. Both canister systems are in structures that require air vents for convection cooling of the fuel.

The proposed Shimkus/Issa bill, H.R. 3053 Nuclear Waste Policy Amendment Act of 2018, now in the Senate, will not solve our nuclear waste storage problems and will make the problems worse.

Those in Congress who support this bill do not know the truth about what is in the bill. The bill promises to move highly radioactive nuclear fuel waste (such as San Onofre nuclear waste) to Yucca Mountain in Nevada, or to consolidated “interim” storage sites, such as those proposed in New Mexico and Texas. Instead, H.R.3053 makes the problem worse.

The official summary of H.R. 3053 and other information provided to elected officials by Shimkus and others does not disclose these facts. H.R. 3053:

Allows ownership of nuclear fuel waste to be transferred to the Department of Energy (DOE) at existing nuclear sites, making us vulnerable to insufficient funding for nuclear waste storage. Current DOE nuclear waste sites have repeatedly leaked radiation into groundwater and air partly because of this.

Share handouts with local, state and federal elected officials and others regarding why they should oppose H.R. 3053 as written and demand the Nuclear Regulatory Commission (NRC) stop approving inferior storage containers. Instead, Congress must mandate that spent nuclear fuel and it’s containment be maintained and monitored in such a manner as to prevent radioactive leaks and explosions in both short and long-term storage. The NRC is currently not doing that. Instead, the NRC lowers safety standards, by ignoring current Nuclear Waste Policy Act law requirements for monitored retrievable fuel storage. This bill would removes those critical safety requirements from existing law.

Attend Coastal Commission public meetings and request permit be revoked.

Ask local and state elected officials to demand the Coastal Commission revoke the permit.

Other countries and some US nuclear facilities use proven thick-wall metal storage casks (10″ to 19.75″ thick) to store their nuclear waste.

They are designed to maintain and monitor the fuel and container.

Thick-wall Areva designed casks survived the 2011 tsunami and earthquake at Fukushima in Japan.

In Japan and other countries, such as Germany, thick-wall casks (both Castor and Areva designs) are stored in reinforced hardened buildings for additional environmental and security protection.

France uses thick-wall casks for themselves and others, but sells their NUHOMS thin-wall canisters to the US. Most US nuclear corporations choose short-term lower costs over quality and safety.

Thick-wall casks are licensed for use in the US and are the oldest and most proven dry storage containers used in the US and elsewhere.

Southern California Edison claims there is no NRC approved thick-wall cask designed for San Onofre is misleading. Fuel assemblies are frequently a different size at different facilities, so it is common to need an NRC license amendment to modify container designs to accommodate this. Edison needed a license amendment for the NUHOMS 32PTH2 canisters they purchased and took delivery of (but never used), and for the Holtec HI-STORM UMAX canister system they ultimately purchased (for a price they refuse to disclose, even though ratepayers are funding them).

Edison’s MPR 2017 white paper recommends using the Test Area North (TAN) Hot Shop — this hot cell was destroyed in 2007!

Edison is using MPR’s September 2017 white paper as their reference for how they can safely manage the nuclear fuel waste and how they can feasibly replace canisters (by shipping them to the TAN hot cell). MPR’s own technical reference (#21) in their white paper states it was destroyed in 2007, yet they claim it’s feasible to use. On page 20 of the MPR report it states: “The DOE recently identified a large existing hot cell facility (Test Area North) on the Idaho National Laboratory (Reference 21) that could be dedicated to repackage commercial used fuel canisters.”

Edison (Tom Palmisano) admitted we would likely need a “hot cell” to transfer fuel from one container to another. This is a dry fuel handling facility filled with an inert gas (such as helium) where fuel is handled remotely. The NRC requires the ability to handle fuel in such a “dry fuel handling facility”, even though one has not been identified that can be used.

Edison should not be allowed to destroy their spent fuel pools until they have a hot cell on-site to transfer fuel to new dry storage containers and to maintain and monitor the fuel and the containers. Edison has not provided a cost for such a hot cell, but has been asked numerous times about this.

The Idaho National Laboratory (INL) Test Area North (TAN) hot shop (hot cell) destroyed in 2007 was the only hot cell identified large enough for unloading large canisters. The MPR Associates white paper “SONGS Used Fuel Management – Defense in Depth”, September 2017, page 20, incredulously states it is feasible to use this TAN hot shop (hot cell) for San Onofre canisters. MPR’s reference for this claim (Reference #21) actually states the opposite right in the summary on Page v — it states the TAN facility was demolished in 2007. The scope of the referenced INL report is not even relevant to using a hot cell to replace failing welded lid thin-wall canisters. The scope was to determine whether “it is possible to receive, open, inspect, remove samples, close, and reseal large, bolted-lid, dry storage casks at INL” Viability of Existing INL Facilities for Dry Storage Cask Handling, USDOE Report, INL/EXT-13-29035, April 2013. This appears to be a significant reading comprehension error with the MPR authors.

Edison knew the TAN facility was demolished, yet did not catch this major error in the MPR 2017 report nor that the INL report was not even relevant to MPR’s claim. Closure of the TAN facility was discussed at the California Public Utilities Commission San Onofre decommissioning proceeding during August 2015 evidentiary hearings.

Evidence from over 4,400 measurements from commercial fuel-rods from reactors around the world show medium and high burnup fuel (>35 and >45 GWd/t) increases fuel cladding oxide thickness. This increases fuel damage and explosion risks from hydrides.

The MPR 2017 report also ignores other evidence that does not fit their conclusion. For example, it ignores risks of high burnup fuel damage by using outdated references. It ignores criticality risks if unborated water enters canisters from through-wall cracks. It ignores hydrogen gas explosion risks. Edison is aware of these risks, yet is promoting this MPR report as evidence they have defense in depth and can only have minor radioactive leaks that they will be able to stop. They have provided no evidence of this — only unsubstantiated promises of future solutions. See High Burnup Fuel Unstable in Storage and Transport for evidence of cracking, leaking and explosion risks.

Edison received defective nuclear fuel waste canisters from Holtec.

Loose bolts were found inside the bottom of some new Holtec canisters. Holtec loaded four San Onofre Holtec thin-wall canisters with nuclear fuel waste before they noticed the loose bolt (pin) in the bottom of an empty canister. Holtec used a new basket shim design. Only the original shim design was approved by the NRC. The four canisters were not inspected by Holtec at San Onofre because Edison said they couldn’t see the bottom of the shims in the canister to know there were pins there let alone missing or bent pins. Learn about other Holtec issues here.

Edison did not notify the public for over a month (on March 22, 2018). They were aware of the problem since February 20, 2018 and had loaded four canisters with the defective new shim design. An evening news report on March 18, 2018 by Mike Faher, VTDigger, in the Vermont Brattleboro Reformer reported the problem. In that article, the NRC refused to name the nuclear plant where the loose bolt was found. It was San Onofre.

MPR was hired by Edison to assess the risks of the defective Holtec new shim design. This is the same company that recommended the INL TAN hot cell as a a possible option for transferring fuel waste to a new container — the hot cell their own reference said had been demolished in 2007. According to Edison, MPR claims the four loaded Holtec San Onofre canisters with the defective shim design are safe. The NRC is still investigation this. However, the NRC has never required any misloaded or otherwise problem canisters to be replaced. Over half the Diablo Canyon Holtec canisters were loaded incorrectly. These were also loaded by Holtec.

This is a Holtec design and quality control problem. No independent inspections are required by the NRC. Holtec was hired to manufacture and load the San Onofre canisters. Edison has resumed loading canisters with the older NRC approved basket shim design while claiming the four canisters loaded with the new defective design are safe.

According to the NRC, Holtec has been using this defective design since 2016. Holtec notified the following sites that have loaded or received canisters with the defective basket shim design: Dresden, Grand Gulf, Hatch, Vermont Yankee, Columbia, San Onofre, Watts Bar and Callaway. No one apparently knows the condition of the four San Onofre canisters or other canisters that may have been loaded with the defective shim design. Vermont Yankee had already loaded 30 canisters, with 15 additional remaining to load. It is unclear which canisters contain the defective new shim design.

The basket shims are 18 foot long hollow aluminum, with over 1/2″ thick walls. The bottom of each shim is supported by only three 7/16″ x 4″ stainless steel pins (bolts). At the bottom of each canister are a total of 88 bolts (pins). The open space at the bottom of the basket shims allows helium to circulate around the fuel assemblies. Source: Nuclear Regulatory Commission and Southern California Edison. Holtec provided most of the information to them. Loose Holtec bolts NRC emails with Donna Gilmore as of March 27, 2018

Technology does not exist to safely store nuclear fuel waste in a permanent repository — even in the short-term,

The Nuclear Waste Technical Review Board December 2017 report to Congress states spent nuclear fuel waste needs to be monitored and maintained in dry storage in a manner to prevent hydrogen gas explosions for both short-term and long-term storage. This is not currently being done and cannot bedone with the thin-wall welded canisters. It can only be done with thick-wall bolted lid casks, like those used in most of the world and at some US facilities. See Nuclear Waste Technical Review Board report to the United States Congress and the Secretary of Energy, Management And Disposal Of US Department Of Energy Spent Nuclear Fuel, NWTRB, December 2017.

The best available current technology solution is to store spent nuclear fuel waste above ground in hardened buildings for additional environmental and security protection. The best available technology that can meet NWTRB requirements are thick-wall bolted lid casks, currently the standard in most of the world (except the U.S.). Most U.S. nuclear waste generators chose thin-wall canister systems because of lower initial cost.

ACTION #3: Educate the public and elected officials.

Please take action to help stop use of these inferior “Chernobyl cans”. This affects you and your family and is a “now” problem. Demand proven thick-wall casks that do not have the design flaws of the inferior thin-wall canisters. Oppose legislation that makes us less safe and does not solve the urgent nuclear waste dry storage problems we now face.

S.B.2396 and H.R.4441 are titled The Safe and Secure Decommissioning Act of 2018, but the opposite is true. The bills encourage expediting highly radioactive spent nuclear fuel out of the pools into dry storage — even in unsafe thin-wall dry storage canisters. Each can contains about as much lethal highly radioactive Cesium-137 as was released from the 1986 Chernobyl nuclear disaster.

Contact local, state and federal elected officials and tell them to oppose S.B.2396 and H.R.4441. Emergency and security regulations and requirements should be continued until all spent fuel is removed from the site. And no thin-wall cracking Chernobyl cans!

These bills propose to eliminate emergency and security regulations and requirements once all fuel at a nuclear plant is in dry storage, even though this lethal highly radioactive spent fuel waste is still at the site.

State and local governments receive millions of dollars in emergency funding from operating reactor corporations (licensees). However, the NRC currently grants exemptions that result in termination of these funds once nuclear reactors are permanently shutdown — even though the lethal nuclear waste is still in our communities and even though state and local governments must respond to radioactive nuclear disasters.

The NRC officially assumes nothing will go wrong once nuclear reactors are shutdown, even thought they know better. See these Comments to the NRC (ML16082A004) as to why NRC’s claimed assumptions are wrong — based on their own evidence.

It appears elected officials sponsoring these bills are believing the wrong “experts”, who are telling them these thin-wall cans are safe enough and safer than the spent fuel pools. However, the pools have defense in depth (redundancies). The thin-wall cans have no redundancies. The fuse is likely lit on these Chernobyl cans, but we have no idea how deep the cracks are to know how much time we have left. The nuclear corporations have no approved plan in place to prevent or stop leaks, criticalities, or explosions. They cannot repair or adequately inspect for cracks. Even partially cracking canisters cannot be transported per NRC regulations. High burnup transport casks require intact canisters (no cracks). Learn more on SOS Holtec webpage.

S.B.2396 and H.R.4441 Bill Summary: This bill amends the Atomic Energy Act of 1954 to prohibit the Nuclear Regulatory Commission from approving the request of a licensee for a waiver of, or exemption from, a covered regulation applicable to a civilian nuclear power reactor that has permanently ceased to operate.

A covered regulation includes: (1) an emergency preparedness or response regulation or requirement, or (2) a security regulation or requirement applicable to spent nuclear fuel.

This prohibition shall not apply to a civilian nuclear power reactor at which all spent nuclear fuel has been transferred to spent nuclear fuel dry casks.

NRC Regulation 10 CFR § 71.85 Packaging and Transportation of Radioactive Materials. Preliminary determinations. Before the first use of any packaging for the shipment of licensed material — (a) The certificate holder shall ascertain that there are no cracks, pinholes, uncontrolled voids, or other defects that could significantly reduce the effectiveness of the packaging.

Edison has not provided evidence to support they can meet Coastal Commission and NRC requirements and recently disclosed plans to destroy spent fuel pools, which is their only currently approved on-site method to replace cracking canisters.

Coastal Commission staff report said cracks would not start for 30 years per the NRC August 5, 2014 document. However, the staff did not report that this was before the NRC knew that conditions for cracking could occur in only two years with temperatures low enough on the canister to dissolve salt particles.

Given this incorrect information regarding 30 years before a crack could start and the fact partially cracked canisters do not have a seismic earthquake rating, the Commission made their decision with incorrect information.

Instead of requiring that Edison solve these problems before granting a Coastal permit, Edison received Coastal Commission permit to load 73 more thin-wall canisters in a partially buried unproven system, with only a promise they will solve these problems. See Holtec UMAX canister system.

The above Google map shows the location of the Southern California Edison San Onofre Nuclear Waste Dump in San Diego County on Camp Pendleton leased land, near the border of Orange County. The Holtec UMAX dry storage system (circled) is under construction with plans to load 73 high level nuclear fuel waste canisters starting in December 2017. Each Holtec thin-wall canister can hold 37 fuel assemblies.

Located directly behind the Holtec system shown above are 51 Areva NUHOMS storage canisters, each stored in a horizontal concrete overpack. Each Areva NUHOMS thin-wall canister holds 24 fuel assemblies. Both storage systems require air vents so the nuclear fuel waste does not overheat. The steel canister walls are only 5/8th of an inch thick and are susceptible to short term cracking. The Areva NUHOMS canister system is approved under separate Coastal permit (No. E-00-014), expires November 15, 2022.

Below is diagram showing distance to water table and surf. System is built half underground with dirt piled up on the sides. The NRC approved generic Holtec UMAX design is for a below ground system with only the top pad and lid above ground. And the NRC and Southern California Edison are ignoring the fact partially cracked canisters have no seismic rating.

Weakens other safety requirements in existing 51 thin-wall San Onofre spent fuel canisters, each holding about as much lethal radioactive Cesium-137 as was released from the 1986 Chernobyl nuclear disaster.

Each canister contains about as much highly radioactive Cesium-137 as was released from the Chernobyl nuclear disaster.

The following federal and state government agencies know these canisters are susceptible to short-term cracks and leaks; that the canisters cannot be inspected (inside or out), cannot be repaired, maintained or monitored to PREVENT radioactive leaks. Edison has no approved plan in place to deal with cracking leaking canisters. Canisters with even partial cracks are not approved for transport and have no seismic rating. In spite of all this, these agencies are allowing Edison to build this nuclear waste dump which the U.S. Nuclear Regulatory Commission acknowledges might stay here indefinitely.

California Coastal Commission: Granted a recent Coastal building permit with the unsubstantiated hope these problems will be solved in 20 years. Granted an earlier separate 20 year permit for the existing 51 Areva NUHOMS thin-wall canister system.

Nuclear Regulatory Commission: Licensed Holtec UMAX storage system. Ignored San Onofre high risk location. Refused to consider canister cracking and other unresolved aging management issues in their initial license approval. NOTE: Edison still needs an NRC site license which must be granted before fuel assemblies can be loaded into the Holtec UMAX system.

California Public Utility Commission:Approved ratepayer Decommission Trust Funds to procure this system. Ignored cost-based case that there are insufficient funds to replace canisters that may fail in the short-term. Ignored Edison’s own testimony that it’s “unlikely” the federal government will take this waste anytime in the forseeable future. Ignored that the Holtec canister warranty excludes corrosion and cracking vulnerabilities. It covers only a limited warranty for manufacturing defects for problems we cannot even see, and this is only 25 years for the canister and void after 10 years, if the concrete structure fails.

Recommendations for Safer Nuclear Waste Storage and Transport

The majority of U.S. nuclear power facilities store highly radioactive nuclear waste in thin-walled canisters (most only 1/2 inch thick) that both the Nuclear Regulatory Commission (NRC) and the Department of Energy (DOE) admit cannot be inspected (on the outside or inside), cannot be maintained, repaired, and can crack and leak in the short-term. Other countries and some U.S. facilities use thick-walled metal casks 10 to 19.75 inches thick that do not have these problems. The NRC has approved thick wall casks in the past and those are still in use, so licensing should not be a problem. Thick casks are proven designs for both storage and transport. Thin-wall canisters must be banned from use before they start leaking radionuclides into the environment. Each canister contains about as much lethal Cesium-137 and other radionuclides as was released from the 1986 Chernobyl nuclear disaster. More details and source links below.

U.S thin-walled canister systems also use aluminum alloy baskets. However, because the lids are welded shut no one knows if there are problems. Japan was able to inspect their baskets because the lids of their casks are bolted instead of welded.

There are no adequate plans in place to prevent or remediate a major radioactive release from these thin-walled canisters. We will only know of the problem after radiation is released into the environment.

Some vendor claims that they can put a leaking canister into a thick sealed transfer or transport cask are unsubstantiated. No such cask is approved for this purpose. A thermal analysis and other evaluations have not been done or approved by the NRC. The NRC evaluated use of a cask at Big Rock Point for temporary storage of a thin-wall canister. They approved it for only 270 days. The NRC was not even sure the radiation levels would be safe doing this. Big Rock has lower burnup fuel (40 GWd/MTU or less) and fuel that cooled for decades in the pool. The NRC allowed Big Rock to destroy their pool with the assumption Big Rock would have a solution after 270 days. However, they don’t; yet the NRC has not dealt with this and continues to let other decommissioning facilities destroy their pools. Fortunately, Big Rock and other utilities have not yet had a leaking canister, However, these thin-wall canisters are near the age where they can start leaking from through-wall cracks. Big Rock Point References:

The NRC no longer requires the fuel assemblies to be retrievable from the canisters (ISG-2, Rev. 2), even though the DOE Standard Contract with utilities requires this.

NRC Director Mark Lombard is responsible for approving this change even though he and others know fuel will eventually need to be retrieved from these thin canisters and the canisters cannot currently be inspected or repaired and may crack and leak in short-term storage. Comments to the NRC regarding the impacts of this rule change were dismissed with bureaucratic double talk.

The NRC also allows empty spent fuel pools to be destroyed at decommissioned plants, even though they know this is the only approved method the utilities have to unload failing canisters.

Each canister contains more highly radioactive Cesium-137 than released from Chernobyl.

Currently there are 50 “Chernobyl” cans with only 5/8″ thick steel walls and one can with other high level radioactive waste. They began loading in 2003.

Southern California Edison is ignoring the problems of thin canisters. Instead they plan to buy almost 100 Holtec thin canisters and store them in an experimental unproven system. Cost is estimated at $4 million each, including labor. Edison refuses to disclose the actual cost, even though this is ratepayer money.

The NRC states once a crack starts it can grow through the wall of the canister and leak in about 16 years. Edison has existing canisters that have been loaded since 2003. Southern California Edison plans to continue to unsafely store over 1600 metric tons of highly radioactive nuclear waste on the Southern California coast even though they know all this.

The Nuclear Regulatory Commission (NRC) approves use of these inferior canisters in spite of knowing these problems. Therefore, it is up to our local, state and federal elected officials, regulators and concerned citizens to take action to address these issues before we have major nuclear radiation releases that can create permanent sacrifice zones in our communities, spread highly toxic radiation into our food supply, and disrupt our economy and transport systems.

Each thin canister contains about as much Cesium-137 as was released from Chernobyl.

There is no approved plan to remediate failed canisters once nuclear spent fuel pools are destroyed, as is the plan at San Onofre and other decommissioning nuclear reactors.

Most other countries use thick walled casks (about 10″ to 20″ thick) rather than the mostly 1/2″ thick canisters used in the majority of U.S. nuclear facilities. Thick walled casks do not have the thin canister problems.Most other countries use thick walled casks.

See more details with government and scientific references below and on the Nuclear Waste page.

San Onofre nuclear reactors have been shutdown since January 31, 2012 and the Nuclear Regulatory Commission (NRC) concluded Southern California Edison was at fault. Therefore, how can we trust them to store the waste safely?

The San Onofre shutdown resulted from decades of excessive wear in both reactors’ (Units 2 and 3) new steam generator tubes, which resulted in a steam generator radiation tube leak on Unit 3 on January 31, 2012. The NRC concluded Edison was at fault: “…a significant design deficiency in replacement steam generators, resulting in rapid tube wear of a type never before seen in recirculating steam generators.” In the NRC’s December 23, 2013 NRC Notice of Violation to Edison, the NRC stated: “…design control measures were not established to provide for verifying or checking the adequacy of certain designs.”

The experience of other facilities substantiates the conclusion that the cost to install an underground dry cask storage system [UMAX] at Vermont Yankee would be considerably more expensive than the above ground HI-STORM 100 system. Additionally, I understand that utilities suing the U.S. Department of Energy (“DOE”) for breach of its contracts to remove spent fuel from their sites are required to take reasonable steps to mitigate the damages incurred as a result of the breach. It is therefore unlikely that the cost of a spent fuel storage system that is significantly more costly than another available alternative can be recovered from DOE. Entergy VY continues to believe that the HI-STORM 100U [UMAX] system not only would be significantly more difficult and substantially more expensive to install than the above-ground HI-STORM 100 system, but also carries significant schedule and cost risks associated with an unproven system.

Edison plans to store the UMAX system partially underground in moist corrosive soil. The system has air vents connected to pipes in the outer lid to cool the thin hot canisters. However, there are no drains for moisture, water or other debris that enters the vents and pipes (downcomers). Water and other debris can accumulate and potentially block the opening at the bottom of the pipes and elsewhere. This can block the air flow of the cooling system. Workers are expected to put hoses down the vent holes and pump out any water or other debris. They will be exposed to some radiation, even when the canisters are not leaking from cracks. Workers will need to manually inspect the vents and pipes to determine if there is any blockage. No other thin-wall canister system or thick-wall cask system has this problem.Learn more…

All thin-wall canisters can crack, but cannot be inspected for cracks (inside or out), and cannot be repaired, maintained or monitored to PREVENT radioactive leaks.

Safety Analysis Report Holtec HI-STAR 190 Package (Revision 1), Holtec Report No. HI-2146214, June 8, 2017 (ML17166A448). The NRC used this document to justify the August 2017 approval of the Holtec HI-STAR 190 for high-burnup spent fuel. The NRC is ignoring its own safety regulations with this approval. For example, the NRC knows there is no current technology that can inspect for cracks in canisters loaded with spent nuclear fuel, yet it approved this. To make matters worse, unloading the canister at the destination location isnotpart of this Safety Analysis Report (SAR). PDF Page 23 states: Any further operations, such as unloading fuel assemblies from the MPC [Multi Purpose thin-wall canister] if that is required, and consideration of HBF [High Burnup Fuel] condition during unloading need to be performed under the jurisdiction of the location where the cask is unloaded, and is not part of this SAR.

Edison is ignoring this data and purchased a Holtec dry storage system that cannot be inspected, repaired or maintained.

Edison has no plans or funding to deal with leaking or cracking canisters.

The nuclear industry does not dispute this. They and their nuclear advocates, such as Community Engagement Panel (CEP) Chairman, David Victor, don’t like us calling these “Chernobyl in a can”. However, their only rebut is stating it’s not a Chernobyl reactor in a can. No, but it contains the amount of lethal radionuclides released from Chernobyl that still contaminate the earth.

It is up to the public to stop this. The NRC ignores their own safety regulations, so we cannot count on them to keep us safe. Learn more and get involved. On this website you will find government and scientific sourced documents that can be used to inform others. Whether you live in California or in other states with nuclear power plants, this affects you, your family and your community.

The California Coastal Commission voted to approve a 20-year permit to install the experimental unproven Holtec UMAX underground nuclear waste thin canister storage system at San Onofre even though they know the system has problems. Instead they added critical “special conditions” that Edison isn’t required to meet for years and it’s unlikely they can ever meet them. Also, these are unfunded conditions. Edison’s cost estimate to the California Public Utilities Commission assumes nothing will go wrong, so it has no funding to remediate problems or relocate the dry storage system on the property, as required by this Coastal permit.

The Commission acknowledged the Holtec system cannot be inspected or maintained. The system is subject to cracking. Cracked canisters cannot be transported. Rather than requiring a system that does not have these critical flaws, they are accepting promises from Edison that these issues will be resolved sometime in the future.

The Coastal Commission should only approve a permit for a spent nuclear fuel storage system that can be inspected, maintained, monitored and transported.

If they have the authority to require these conditions in 20 years, they can require them now.

The Coastal Commission should not lower their standards just because Edison chose an inferior thin canister system that does not meet these critical requirements.

Thick metal cask storage options are available that meet Coastal Commission requirements now and can be deployed in a reasonable time frame. This is proven technology used throughout the world and in the U.S.

Summary of Special Conditions:

Special Condition 2, which authorizes the proposed development for a period of twenty years and requires SCE to return for a CDP Amendment to retain, remove or relocate the ISFSI facility, supported by:

(i) an alternatives analysis, including locations within the decommissioned Units 2 and 3 area;

(ii) assessment of coastal hazards and managed retreat;

(iii) information on the physical condition of the fuel storage casks and a maintenance and monitoring program; and

(iv) proposed measures to avoid/minimize visual resource impacts.

Special Condition 7, which requires SCE to submit, as soon as technologically feasible and no later than October 6, 2022, a maintenance and inspection program designed to ensure that the fuel storage casks will remain in a physical condition sufficient to allow both on-site transfer and off-site transport, for the term of the project as authorized under Special Condition 2.

Special Condition 3, which requires SCE to agree to not enlarge or replace the existing NIA seawall for purposes of protecting the proposed project from coastal hazards.

Special Conditions 1, 4, 5, and 6 which require evidence of the Applicant’s legal ability to undertake the development as conditioned by the Commission, assumption of risk, liability for attorney’s fees, and restrictions on future development.

Take Action

The Coastal Commission granted a 20-year permit for a system that cannot be inspected for cracks, cannot be repaired, may crack in 20 years (or sooner for existing thin canisters) and cannot be transported with cracks.

Tell your local and state elected officials to urge the Governor, the Coastal Commission and the CPUC to NOT allow a nuclear waste storage system to be installed that can crack, that cannot be inspected for cracks, cannot be repaired or maintained and cannot be transported. Tell them to:

not approve a system based on vaporware — capabilities that do not exist. It is against state government regulations to procure vaporware, so why are we allowing Edison to do this? We’ve had enough broken promises from Edison, the federal government and the nuclear industry, so we should not continue to rely on their promises of future solutions.

Other options are available now, but Edison refuses to consider them.

The NRC approves systems for 20 years even though they don’t meet these requirements. However, it is within the states jurisdiction to require a system that is guaranteed to last decades and won’t affect our coastal resources and communities. The NRC would approve such a system, but Edison needs to ask for it.

Edison should be required to prove they can meet the special conditions prior to the installation of the system, not 20 year later.

The Coastal Commission included “special conditions” that must be met AFTER 20 years, including ability to inspect, repair, maintain and transport. If they have the authority to include these special conditions now, then they should require them NOW not in 20 years when it’s too late.

The CPUC will be making a decision on whether to give Edison the almost $1.3 billion of our limited ratepayer trust fund to install and manage this inferior system. Edison’s Tom Palmisano said Edison has no money allocated to relocate this system to higher ground as required by one of the special conditions.

The EPRI report he sited saying there would be no problems for at least 30 years excluded the Diablo Canyon and Koeberg data. EPRI cherry-picked the data in that report, even though the Diablo Canyon data is EPRI data.

The method used to inspect empty thin canisters for cracks (putting a fluid dye inside the canister) will not be one of their solutions. All the other inspection technologies, even if they find a way to do them, will not be sufficiently reliable.

The Holtec UMAX system approved by the NRC is different than the design planned for San Onofre. However, Lombard said they only plan to review the changes and inspect it after it is built.

The Coastal Commission staff report identified these critical problems. However, it was clear from the “likely impossible to meet” special conditions and setting the scope of review to only 20 years, that this decision was made above their level.

Identifies major obstacles to relocating fuel off San Onofre and recognizes fuel may need to stay here indefinitely.

Recommends San Onofre sites that do not require additional environmental and seismic analysis or review.

Doesn’t mention that even though a NRC general license for the ISFSI site allows them to store fuel without a public hearing and NRC prior approval, they still need a licensed product and must following the technical specifications of that license and perform a site specific analysis. The proposed Holtec UMAX system does not meet NRC approved technical specifications. The NRC plans to inspect the system before fuel is loaded to ensure it complies with the technical specifications — however, this is AFTER it is built. See Holtec UMAX not approved for San Onofre.

Below is the proposed location for the Holtec HI-STORM UMAX thin “underground” spent fuel canister system at San Onofre. Half under ground, and close to the water table and about 100 feet from the ocean. Edison admits the Sea Wall hasn’t been maintained so can’t be counted on for protection. This plan doesn’t meet Coastal Act requirements, but Coastal Commission staff think there are no other options, but there are.

Presentation to the Coastal Commission on why they should deny the Coastal Permit, Donna Gilmore, October 6, 2015

The Coastal Commission should not approve vaperware (technology that doesn’t exist) nor make decisions based on unsubstantiated hope.

Coastal Commission staff recommend kicking the can down the road and approving the permit with the condition that Edison will figure out how to inspect, repair and maintain this inferior system after 20 years.

Would you buy a car that cannot be inspected, maintained, repaired and has no early warning system before the car fails? That is what the Coastal Commission is allowing if they approve this Coastal Development Permit.

Edison claims they can relocate the system to another spot a few feet away if the coast erodes and the sea rises. That would cost hundreds of millions of dollars with the current Holtec system (it must be rebuilt) and we all know who will pay for that. Edison plans to spend all the Decommission Trust Fund money and they have not allocated any funds for this.

The Coastal Commission should require Edison have a ready plan for existing canisters that may leak in as little as 5 years and not allow over 20 years before Edison must have an approved plan.

Why when the Coastal Commissioners know these canisters cannot be inspected and are subject to cracking would they approve a Coastal Permit? Listen to Commissioner Shallenberger grill NRC Director Lombard:

Are California and other U.S. nuclear spent fuel waste canisters cracking?

Microscopic stress corrosion cracks can release radiation

No one knows because there isno technology to inspect or repair cracks in thin stainless steel canisters filled with spent nuclear fuel waste. (Share handout)

Koeberg is located in a similar corrosive marine environment as San Onofre and Diablo Canyon: on-shore winds, surf and frequent fog. The Koeberg container had cracks up to a depth of 0.61″. The San Onofre canisters are only 0.625″ thick. The canisters at other California locations, such as Diablo Canyon, are even thinner (0.50″). There are over 2000 loaded canisters in the U.S. Most are 1/2″ (0.50″). More…

Southern California Edison, PG&E and other U.S. utilities have no adequate plans to replace cracked canisters and monitoring system only alerts us after canisters leak radiation into the environment. The only proposed “solution” is to put the cracked canister into a thick cask, with no plan of what to do with it next. There is no NRC approved cask design or procedure for this purpose. It would not solve the problem of needing to replace canisters in case of failure or to meet current Department of Energy (DOE) and Nuclear Regulatory requirements. Cracked canisters are not approved for transport.

Holtec UMAX storage system has air vents in top for convection cooling. Drawing shows drain that does not exist and doesn’t show air vent pipes. Water and other debris can build up at bottom of hole and block air vent pipes, causing overheating. Water and other debris must be pumped out through air vents.

Edison plan to spend almost $1.3 billion of ratepayer funds to store and manage 1680 metric tons of San Onofre nuclear waste in thin 5/8” steel canisters that may crack within 20 years after loading. Their $1.3 billion plan assumes no canister will fail. And they want us to buy vaporware — a product with a vendor promise of a future solution for finding and measuring cracks. Even if they manage to find a solution, there is still no repair solution and nothing to stop them from cracking.

The unproven experimental Holtec UMAX underground storage system Edison plans to buy has never been used or tested anywhere in the world and has not yet been approved for high seismic areas. Missouri Callaway nuclear power plant installed the underground system recently. Tentative first spent fuel loading is July 2015. The thin welded canisters are to be inserted in steel lined concrete holes. The unsealed thick top lids have air vents, so the thin canisters and spent nuclear fuel waste do not overheat.

The NRC approved a Holtec license amendment to use the Holtec HI-STORM UMAX system in high seismic risk areas effective September 8, 2015.However, it is not approved for any specific site, including San Onofre; that requires additional approvals. And they are only certified safe for 20 years. Any issues that may occur after 20 years are not considered by the NRC, even though they know they must last for decades and they do not have aging issues resolved. See more details below and on Nuclear Waste page.

Excludes site approval, such as San Onofre. This requires additional approvals.

Certified safe for only the initial 20 years. Ignores aging management issues.

Excludes any plan for storing failed (cracking) canisters. No vendor casks have been approved for storing or transporting failed canisters and no vendor has submitted an application for this purpose.

Approved for 0.5” thick canisters – not the 0.625” thickness San Onofre proposes. The NRC has not received a License Amendment Request from Holtec for the 1/8″ thicker canister design. This process can take up to 18 months.

The underground system design certified is different than the system design proposed for San Onofre. The San Onofre design is only partially underground.

Conditions for cracking were found on a Diablo Canyon canister in service for only two years. No one knows if it is cracking due to the inability to inspect for cracks, but they know it has all the conditions to initiate cracks. The Diablo Canyon nuclear power plant is located near the Pacific Ocean in San Luis Obispo County. Salt in marine environments can corrode these stainless steel canisters and leads to “chloride-induced stress corrosion cracking.” Numerous other environmental factors can corrode thin steel canisters and their concrete overpacks, but the NRC has not fully evaluated these yet. More…

The thin canister vendors, nuclear industry and utilities, and others ignore the Diablo Canyon and Koeberg data when they make unsubstantiated claims these canisters will last. They will claim they are not aware of any cracking problems. That’s because they do not have technology available to inspect for cracks or to measure crack depth. More…

The NRC staff finds that the schedule for decommissioning activities is adequate to achieve SONGS, Units 2 and 3, license termination within 60 years of permanent cessation of operations (June 2013), as required by 10 CFR 50.82(a)(3). However,the NRC considers out of scope of this review“questions or comments about the performance, design requirements, and the availability of inspection and repair methods of spent fuel storage casks previously certified or under review by the NRC (Note: these issues are addressed during NRC’s licensing of the spent fuel storage casks, or during cask license renewal).”

The NRC staff finds the SONGS IFMP estimates to be reasonable, based on a cost comparison with similar decommissioning reactors, while acknowledging that there are large uncertainties and potential site-specific variances that may impact these cost estimates in the future.

The NRC staff has determined that storing fuel in either the spent fuel pool or ISFSI represents an acceptable means for storing irradiated fuel. The licensee’s plan contains both storage methods, with irradiated fuel being taken out of the spent fuel pool and fully transitioned to the ISFSI within 5 years, followed by complete dry storage.

The anticipated date to transfer fuel to DOE and subsequent decommissioning of the ISFSls are scheduled to be completed in 2051. This supports the requirement to complete decommissioning within the 60-year timeframe, as required by 10 CFR 50.82. [This schedule assumes there will be a place to start sending this fuel by 2024, which Edison’s own witness said was “unknowable” and unlikely]. It also assumes fuel assemblies will not need to be reloaded into DOE approved casks. Current DOE standard contract requires this.

California Public Utility Commission (approves funds)

Specifically, the Commission must determine if the applicants have
justified the Nuclear Decommissioning Cost Estimate, the proposed adjustments
to contributions to the Nuclear Decommissioning Trust, and processes for annual
review of decommissioning cost expenditures.

Edison must also justify its proposed balancing account for unanticipated decommissioning costs, and SDG&E its share of the decommissioning costs and proposed revenue requirement.

The reasonableness of the Nuclear Decommissioning Cost Estimates does
not include operational decisions, such as vendor selection or equipment
specifications, but does include the soundness of cost assumptions andcontingency planning.

California Coastal Commission (enforces Coastal Act)

Otters 4077 Cleve Nash

Edison submitted an NRC License Amendment Request on August 20, 2015 to lower safety standards for spent fuel pool cooling so they can install a air-chiller system that doesn’t meet nuclear grade standards, including earthquake standards. At the August 13, 2015 Coastal Commission meeting, the Coastal Commission approved a permit for this cooling system. However, it was based on assurances from Commission staff and Edison that it met high seismic standards. Therefore, this decision should be reversed.

Staff Report and Recommendation for use of experimental air chillers (similar to fish aquarium chillers) to cool the spent fuel pool water. Air chillers have never been used for this demanding application.

The (1/2 – 5/8 inch) thin stainless steel canisters storing radioactive nuclear waste at U.S. nuclear power plants may fail within 30 years. There is no current replacement plan. Waste may need to be stored at nuclear plants sites for over 100 years. Once canisters are loaded with waste, they are no longer inspected for aging or monitored for helium leaks. These are just some of the problems with U.S. dry storage systems. More…

This is SanOnofreSafety.org founder Donna Gilmore’s presentation to the NRC on dry cask nuclear waste storage issues, delivered by invitation as part of an NRC Regulatory Conference held Nov. 19-20, 2014 in Rockville, Maryland. Why are the NRC and Southern California Edison favoring inferior, short-lived, thin-walled, unsafe stainless steel canisters to store San Onofre’s tons of nuclear waste in a corrosive seaside environment instead of the long-lasting, thick-walled, top-of-the-line technology available?

Gilmore presents a strong case for regulators and utilities to take the lead in setting the highest possible standards for America’s growing inventory of radioactive waste that will remain deadly for hundreds of thousands of years longer than human civilization has yet existed. With no safe long-term storage sites having been found despite over half a century of attempts to find them, Gilmore urges officials not to ‘play bureaucratic roulette’ with the future of California and the rest of the nation.

Thanks to EON3 for producing this video. EON3 is a non-profit organization that can use your help to support producing more videos like these. Please donate to EON3 here.

Nuclear industry vendor, Areva, admits to having no answer to replacing failed nuclear waste storage canisters once spent fuel pools are destroyed. NRC admits to no current method to inspect for cracks in nuclear waste canisters.

HIGH BURNUP FUEL: San Onofre and other U.S. reactors switched to more dangerous high burnup nuclear fuel over a decade ago. High burnup fuel is low enriched uranium that has burned longer in the reactor than lower burnup fuel.

It’s hotter and over twice as radioactive as lower burnup fuel and unpredictable and unstable in storage and transport. The protective Zirconium fuel cladding is more likely to become brittle and shatter.

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Worst safety complaint record in the nation!

The San Onofre Nuclear Power Plant has the worst safety complaint record of all U.S. nuclear reactors according to Nuclear Regulatory Commission (NRC) safety allegation data. See charts for details.Employees are retaliated againstfor reporting safety problems. SeeSafety Allegations Sectionfordetails on this and other safety complaints by employees and others. More…

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Worst safety complaint record in the nation!

The San Onofre Nuclear Power Plant has the worst safety complaint record of all U.S. nuclear reactors according to Nuclear Regulatory Commission (NRC) safety allegation data. See charts for details.Employees are retaliated againstfor reporting safety problems. SeeSafety Allegations Sectionfordetails on this and other safety complaints by employees and others. More…

The majority of spent nuclear fuel at San Onofre falls into the danger zone as shown by the yellow in this Waste at SONGS chart.

Burnup levels as low as 30 GWd/MTU show indications of damaging the protective Zirconium cladding.

Other U.S. nuclear plants have spent fuel that falls within the danger zone, including Diablo Canyon in San Luis Obispo County. More…

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California has excess power without California’s unreliable nuclear power plants, even during peak summer months, according to California government documents. There should be no power problems with San Onofre shut down, even during the summer. And the California ISO’s electricity grid Transmission Plan says there will be no grid stability concerns with San Onofre shut down. More…

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San Onofre Nuclear Power Plant

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10 and 50 mile evacuation zones

Nuclear meltdown at San Onofre would poison the nation’s food supply, create permanent “dead zones” and create financial ruin around the nation. If you live within 50 miles of San Onofre, you are at even higher risk of losing everything you care about here. Five counties are within the 50 mile zone: Los Angeles, Orange, Riverside, San Bernardino and San Diego.

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There is no safe level of radiation, according to the National Academy of Sciences.Children, unborn babies and women are more susceptible to the effects of radiation. Ingesting radiation is extremely dangerous. More…

Photo of children tested for radiation near Fukushima Daiichi nuclear plant in Japan (Kim Kyung-Hoon/Reuters)

The map shows most of Southern California is at the mercy of the wind in the event of a nuclear disaster at San Onofre. The long arrows that point SW and SSW represent the offshore winds at night but those winds turn onshore when the inland areas heat up in the morning.

What if the Fukushima nuclear fallout crisis had happened in California? These radioactive plumes from severe nuclear accidents were calculated by NRDC based on the actual weather patterns of March 11-12, 2011. The result on any given day will vary according to the type of reactor accident and on the prevailing weather patterns at the time. These plumes artificially extend only to 50 feet. Winds can carry them further. See NRDC interactive U.S. map.

This map shows the wind rose from the January 2011 San Diego County Nuclear Emergency Response Plan superimposed over the 160 mile evacuation zone contemplated by the former Prime Minister of Japan Naoto Kan and his nuclear experts in the early days of the triple meltdown at Fukushima Daiichi in March 2011 when TEPCO was about to abandon the out of control power plant.

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This is an essential web site. I have shared it with friends and have asked them to forward it to their friends. This site will be a powerful tool in getting the job done — closing the doors on SanO and creating a safe haven within all of Southern California. Julie Tully

Statement of Concern:
ROSE believes that the NRC’s stated alternative to Change the Waste Confidence away from the small step approach to the long-term Waste Confidence program for 200 years to make nuclear power plant sites into nuclear waste dumps for 200 years is shortsighted and completely without regard for the safety of the millions of citizens who populate the areas around these power plants.
This type of decision by the NRC, demands that the public take action to secure its own safety from the hazards of such a nuclear waste dump in their vicinity wherever it is located. It calls into question the very mandate itself of the NRC “Protecting People and the Environment” and leads us to the conclusion that the NRC is no longer capable of Protecting the People and the Environment. This may mean it is time to consider disbanding the NRC and forming a new protective agency led by the citizens themselves who have no vested interest in protecting the nuclear industry.

NRC Draft Report for Comment Dec 2011 Waste storage policy. Background and Preliminary Assumptions For an Environmental Impact Statement.—Long-Term Waste Confidence Update. States
6. Alternatives Under the National Environmental Policy Act
“The proposed action is a change to the Commission.’s current Waste Confidence decision and rule, which requires the Commission to revisit the issue of Waste Confidence every five to ten years. As part of this process, the Commission has revised Waste Confidence twice since 1984, and each time has expanded the temporal scope of its analysis by a few decades. This long-term Waste Confidence update would move away from this small-step approach, and would extend the temporal scope of Waste Confidence by as many as 200 years. The EIS will include an analysis of the impacts of four storage scenarios in order to assess the magnitude and range of impacts and the safety of extended storage. Section 8 of this report discusses these scenarios. As with the current Waste Confidence rule and decision, the Waste Confidence EIS will generically describe the potential impacts of extended storage and will assume that the storage of spent nuclear fuel will continue to be a regulated activity in the future. Unlike the current Waste Confidence rule and decision, this long-term Waste Confidence EIS will not require reconsideration of a possible update to the rule and decision every five to ten years.

We now are being ruled by those in Nuclear Denial*; instead of by Leaders that demand an end to the Trillion Dollar Eco-Disast­er RISK that Nuclear poses to mankind! The nuclear industry is fighting tooth and nail to maintain it’s market share; yet NOW Solar (of all flavors) is far less costly to construct, faster to construct and carries with it N☢ Nuclear radioactiv­e baggage that can kill a Countries economy and or those living nearby!
Ask The Japanese!

*Nuclear Denialhttp://is.­gd/XPjMd0
The illogical belief that Nature cannot destroy any land based nuclear reactor, any place anytime 24/7/365!

Many, many more would install Solar if the Utility paid those that installed Solar for the energy they put INTO the grid, at the very same rate that the Utility charges for that same Energy to folks that take Energy OUT of the Grid! By not paying the same amount, the Utility shareholders receive additional money they do not deserve and the folks that have installed solar end up with a much longer payback period!

We’ve had a solar system for 6 years now, and we’re connected into the grid. Essentially we use the grid, instead of batteries. Feeding our excess in and drawing our shortfall. On an annual basis we about break even.

I wanted to let you know though, that we have a net metering agreement with SCE and we are paid the same $amount/kwh for our production and usage. That’s why we opted for our grid-tie in. Which utility does not pay the same amount that they charge?

Incidentally, we financed our system (when home equity loans were still available) so that our monthly payment equalled our average electricity bill. That way, we ensured that so long as our consumption levels did not increase, neither would our electricity cost. It’s worked out great for us.

Incidentally, when we designed our system we were advised to underproduce, just a bit. This is because the utilities would not reimburse for our overproduction. However, Schwarzenegger changed this on his way out with a program to provide payment for net surplus generation.

Contrary to all the bad press, solar has actually been a great investment on many levels for this middle-income family.

Hey John – I’m not sure about that. Essentially our meter spins backward or forward depending upon our usage. We’re charged the kwh rate for our annual consumption (production is already deducted out on a kwh basis, so I don’t think a distinction is made for pricing consumption/production… the net amount is simply billed at the tier rate where it falls. I will call SCE net metering and ask for confirmation though.

Regardless, it’s saved us a ton of money over the 7 years since we’ve had it installed. Our electricity cost has not increased, while we’ve watched our neighbors’ electricity bills skyrocket.

Specific to your concern though, check out the article linked above – looks like LADWP solar customers have got some good news coming their way.

Yes, you are right in that you offset your use. However any excess energy that exists at your Tru Up Period, once a year is only paid in cash to you at a rate of approx. .037 cents per kwh. Typically SCE bills first tier customers 4 plus times that value.

Joe – That may very well be the pricing structure for the annual net production surplus. However, the pricing is equal for the production/consumption throughout the year, which is absolutely the primary concern for a residential application. We installed our solar photovoltaic system in order to reduce our consumption of electricity from polluting sources and to reduce our electricity cost. We have accomplished both, and that really should be the message to people who are considering installing solar panels at their residences. To restate an earlier post, when we installed the system 7 years ago the utilities were not mandated to reimburse us for any annual surplus electricity fed into the grid… and we installed the system anyway because selling annual surplus electricity was not an income producing goal of ours. Even without that “gravy,” we have come out ahead.

I’ve got to say, I don’t begrudge SCE for not voluntarily paying us their retail rate for our annual overproduction, because it would be a bit like expecting Vons to pay me the retail rate they charge for oranges for all the oranges I bring to them off my backyard tree.

Agree, my solar provides all my needs–plus excess I supply to the grid.

My point is fair compensation for excess was suppressed by SCE, SD&GE, ahd PG&E with complicity from the CPUC. If you look at the German model fair compensation is paid for excess energy thus promoting the installation of solar—not nuclear sources.

I believe that once California consumers and especially California property owners realize that they are NOT covered for any type of fallout, leakage or contamination caused by radioactivity, they will begin to reexamine their “trust” in nuclear because of their financial liability!

Question: How many in Southern California (for example) could afford to just walk away from their homes if one of the reactors in California had a meltdown for any reason; without even considering the health implications later? The answer of course is NOT MANY! We have only to see what has happened in Japan to get a good idea; in short America cannot afford a Trillion Dollar Eco-Disaster any better than Japan.

Remember most of the “rest” of America is downwind from the West Coast! Japan has been “lucky” in that regard ,since most of its radioactivity has move toward eastward North America and the rest of the planet; yet most of Northern Japan is now contaminated!

I too have been watching since 3/11 and Japans Trillion Dollar Eco-Disast­er has also affected many of us globally!

I have considered myself a supporter of Japan and Japanese products for a very long time but 3/11 has fundamenta­lly changed my opinion of the Japanese Gov’t !

I never considered that the Japanese Gov’t. would allow global radioactiv­e pollution to “be made in Japan” yet after 11 months it still continues, PLUS the ongoing radioactiv­e pollution continues to be covered up and or SPUN by TEPCO, with the Gov’t.’s approval!

What I now understand is that the Japanese culture is lacking something very basic, which is the ability to just say NO! By not being able to say NO, the Japanese people have no way to guide their Leaders or change their Countries Policy! Japan is doomed to additional suffering because Man cannot control Nature, despite what all nuclear engineers say… Nature can destroy any land based nuclear reactor, any place anytime 24/7/365!

I was there and I could tell you tales that would curl your hair. She is 100% correct.

The plant is only as safe as the people who operate it. For DECADES the place has been diseased with an epidemic of autocratic egomaniacs, ‘rank and file’, ‘good old boy’ entitlement mentality. Juvenile politics rules that place. Not ethics or morals.

For decades every independent audit has concluded that the plant is way too top heavy (too many supervisors and managers). And every time to ‘counter’ the findings, they play name games and staffing roulette to shuffle everyone around until they ‘make everything look right.’

I have pointed out to many people but few have heard me. San Clemente Island (to the lower left of the map up above) has a fault line running right along the eastern side of the island. That side of the island is sheer as it if broke away and slid off to the right of the island in two large movements like this <. Look at the chart and you can see the underwater mounds of what obviously was the northern and southern end of what used to be the eastern half of San Clemente. Once you see it, pay attention. I have been on the island. There is a fault clearly visible on the northern half of the island. It is hard to see on the southern half, but it looks like it is trying to split San Clemente in half again from North to South. If even one half of the northern eastern part of the island fell into the ocean, it would generate a tsunami like wave that could be sixty or seventy feet high. Now, look at the underwater topography of the ocean floor and you will see that THAT WAVE would have a clear shot at the coast right were San Onofre Nuclear Power Plant is located. Now, I know a geologist will tell you that THAT will not happen for 10,000 years and he will probably be right, but I would feel a lot more safer if that Nuclear Fuel was not there in the first place.

Let’s get San Onofre shut down! I figure that the San Onofre plant over the past 40 years has killed close to a million people with radioactive particulate discharge. Remember, Radioactive Particulate gets discharged to the environment when Uranium is dug up from the ground, and when it is shipped, and when it is processed, and when the nuclear plant is in operation, and when waste products are stored, and when the fuel is stored and when it is reprocessed and shipped elsewhere and so on. It is just a never ending nightmare of constant pollution of the environment. Most of that pollution ends up in the soil, and then in our food (both animal and vegetable) and then inside us. Once that radioactive particulate decays in our body it is 400 to 500 times more likely to cause cancer than just an ordinary Cosmic Radiation strike coming from outside the body. As I keep on telling people, the horrific Eight Fold increase in Cancer in the past century is largely do to radioactive particulate in the enviroment and in our bodies. The three largest sources of that radioactive particulate have been the Nuclear Industry, the Coal Industry and the Tobacco Industry (radioactive Lead and Polonium is in tobacco smoke. Thank God, people have cut back in smoking and the lung cancer rate has fallen proportionately.)

Even if we were to shut down the entire nuclear industry today, the pollution of the environment will remain for thousands of years continuing to kill and cause DNA damage for thousands of years, as well. Not only have we had an 8 fold increase in Cancer in the past century, we have had a tremendous increase in DNA damage related illnesses. Every year the medical industry is discovering new illnesses that are caused by radiation strikes in developing ovas and sperm cells. Once a child is created with one of those defective ovas or sperm, it can develop the new genetic illness or it can be a carrier of a new genetic illness and can pass it on to future generations. Having these new genetic illnesses is not a curse from God. IT IS A CURSE FROM MAN, and it will continue to curse man for thousands of years and endless generations as long as people carrying those DNA defects continue passing those defective genes on to their offspring.

Energy made $$$$, getting rid of a plus 20,000 year problem is deadly & will cost the hole planet $$$$$$$$$$$$$$$$ & death of a planet. Can terrorists use nuke waste for a dirty bomb?
For now we can use it in tooth paste!

We still need to keep fighting this battle until the job at hand is finished.
Contact Senator Boxer and tell her that you are relying on her, and the NRC oversight committee she chairs in Congress, to take appropriate measures to protect southern California from a potential nuclear disaster.

Thanks Donna Gilmore for being faithful in fighting against the disastrous problem of using filthy nuclear fission reactions on earth and even near population centers like San Clemente. The created plutonium should never have existed in the first place and now we are forced to somehow figure out what to do with it. There has never been an answer and “nuclear engineers” would never be stopped from developing these facilities while they assumed “someone” would “someday” have an answer. The lethal filth they have created, they themselves are powerless to remedy. Hiding the solid filth in caverns in New Mexico is the method used by the military for nuclear bomb waste. But the gaseous emissions that have gone on at an San Onofre and other locations like it have already occurred. It is a misuse of the term “science” to claim these are “nuclear power plants,” as though they can simply be switched off when they become useless.
We are opposed to Iran building these plants and the U.S. needs to oppose them here as well. The direct dumping of radiation waste from these plants into the Atlantic Ocean by nuclear “scientists” in France is an international travesty. Accidents are one thing, but intentional disbursement is a complete lack of understanding of physiology on the part of the perpetrators. France is one of my favorite countries due to Joan of Arc, Normandie, etc., so this hurts.

LIES! The radiation leak is coming from much much closer. Don’t let the media lie to you. The leak started before Aug 7th, 2013. My father was killed for his knowledge on the leak. The leak is located at S.O.N.G.S. San Onofre Nuclear Generating Station, and is leaking right next to the most popular beaches in California. My father was Scientist #3 / Attorney Jeffery Thornton Allen. They told us he hung himself in his closet, but he was the Attorney on the lawsuit against Mitsubishi for 42 Billion dollars. He knew of all mistakes made by the plant and all precautions involved. He knew too much and was completely against any cover up. Which is why they ended his life. Their intention is to pass the buck onto Japan and blame it on a tsunami, when in fact both plants started leaking at the same time and no tsunami ever hit Orange County. My father knew that Mitsubishi was in charge of the containment of both nuclear plants, and I can’t wait for the day my family sees restitution. Truth.

I miss the damage nuclear waste storage spread around on the genes/DNA of newborn from fathers living ~5km to 40km away from the storage facility.*)
Important as that increased DNA damage transfers to next generations!

While the thick-walled dry casks (castors) are inside a big building with 50cm thick armed concrete walls and (20cm thick) ceiling. But the natural ventilation to transport the castors generated heat out of the building. But that air contains increased levels of argon41 due to collision with neutrons which escaped from the castors. Part of the neutrons also pass through the concrete ceiling and the walls. Pictures of the building in the recent annual radiation measurement reports: http://bit.ly/1NYNaMw

You may assume that the US thin-walled casks emit more neutrons as their walls absorb far less. Furthermore that placing them in the open air contributes further to increased DNA damage.

___
*) http://bit.ly/1HC0N2M
Research and theory show that DNA of the sperm of fathers living 1-5km away is hardly affected by the escaping neutron-argon41-gamma mechanisms, just as that from fathers living >40km away (theory starts at sheet 21): http://goo.gl/URQ6vA

**) The large building (500x20meter) contains only 113 castors. It was closed after a discussion process taking a few years.
An important factor were the damaging results of the due diligence study with extra scope, by authors who were convinced that the waste storage couldn’t create DNA damage so far away (and no damage nearby). To their unpleasant surprise, they found even stronger DNA damage in the added areas. The m/f sex ratio of newborn increased from ~1.02 towards 1.13 in areas 20-30km away (more increase downwind in line with theory): http://bit.ly/1Qs4bjU

Authorities then organized a conference with all parties: http://bit.ly/1MjKRBA
(PPT’s used at the conference in the link at the bottom of the page).
The discussion was won by Scherb etal as those got the assignment for the final report (Oct’14): http://bit.ly/1N8CYT3
Resulting in the premature closure this summer by federal government: http://bit.ly/1PxHwlX

– Sperm is produced via extreme high frequent cell division and at cell division DNA cannot be repaired as it is then single stranded. So at the moment of production sperm is very sensitive for radiation, even far more than fetuses!
Produced sperm dies within a week in the body of the father (unless used for conception, etc).
So the father’s position (irradiation) in the days & hours before conception is the most relevant variable. Birth registers contain the place where the parents live.

– female DNA in sperm is ~3% larger. So when 50% of all female DNA is damaged deadly, the m/f sex ratio increases ~3% as male DNA has a 3% lower chance to be hit by a radiation particle. The av. increase in m/f sex ratio in the zone up to 40km away was 6%, which implies roughly that the DNA was killed in 75% of the sperm cells. However, when hit by a radiation particle DNA is often only damaged, which implies that the newborn has significant higher level of damage in his DNA.

– this m/f sex ratio increase is already noticed in the 1958 UNSCEAR report to the UN general assembly. It is also found elsewhere. E.g. Sellafield workers operating in radiation areas get 30% more boys than girls, etc.

I miss the damage nuclear waste storage spread around on the genes/DNA of newborn from fathers living ~5km to 40km away from the storage facility.*)
Important as that increased DNA damage transfers to next generations!

While the thick-walled dry casks (castors) are inside a big building with 50cm thick armed concrete walls and (20cm thick) ceiling. But the natural ventilation to transport the castors generated heat out of the building. But that air contains increased levels of argon41 due to collision with neutrons which escaped from the castors. Part of the neutrons also pass through the concrete ceiling and the walls. Pictures of the building in the recent annual radiation measurement reports: http://bit.ly/1NYNaMw

You may assume that the US thin-walled casks emit more neutrons as their walls absorb far less. Furthermore that placing them in the open air contributes further to increased DNA damage.

___
*) http://bit.ly/1HC0N2M
Research and theory show that DNA of the sperm of fathers living 1-5km away is hardly affected by the escaping neutron-argon41-gamma mechanisms, just as that from fathers living >40km away (theory starts at sheet 21): http://goo.gl/URQ6vA

**) The large building (500x20meter) contains only 113 castors. It was closed after a discussion process taking a few years.
An important factor were the damaging results of the due diligence study with extra scope, by authors who were convinced that the waste storage couldn’t create DNA damage so far away (and no damage nearby). To their unpleasant surprise, they found even stronger DNA damage in the added areas. The m/f sex ratio of newborn increased from ~1.02 towards 1.13 in areas 20-30km away (more increase downwind in line with theory): http://bit.ly/1Qs4bjU

Authorities then organized a conference with all parties: http://bit.ly/1MjKRBA
(PPT’s used at the conference in the link at the bottom of the page).
The discussion was won by Scherb etal as those got the assignment for the final report (Oct’14): http://bit.ly/1N8CYT3
Resulting in the premature closure this summer by federal government: http://bit.ly/1PxHwlX

– Sperm is produced via extreme high frequent cell division and at cell division DNA cannot be repaired as it is then single stranded. So at the moment of production sperm is very sensitive for radiation, even far more than fetuses!
Produced sperm dies within a week in the body of the father (unless used for conception, etc).
So the father’s position (irradiation) in the days & hours before conception is the most relevant variable. Birth registers contain the place where the parents live.

– female DNA in sperm is ~3% larger. So when 50% of all female DNA is damaged deadly, the m/f sex ratio increases ~3% as male DNA has a 3% lower chance to be hit by a radiation particle. The av. increase in m/f sex ratio in the zone up to 40km away was 6%, which implies roughly that the DNA was killed in 75% of the sperm cells. However, when hit by a radiation particle DNA is often only damaged, which implies that the newborn has significant higher level of damage in his DNA.

– this m/f sex ratio increase is already noticed in the 1958 UNSCEAR report to the UN general assembly. It is also found elsewhere. E.g. Sellafield workers operating in radiation areas get 30% more boys than girls, etc.

I am glad that you re getting the deserved credit and recognition: https://youtu.be/ktNTtpiJpoU
However, I don’t buy that they didn’t know! Hydrogen attack and corrosion are basic problems – they are a bigger problem for nuke industry but problem for petroleum pipelines and cars, etc.